United States securities and exchange commission logo February 19, 2021 Satya Nadella Chief Executive Officer Microsoft Corporation One Microsoft Way Redmond, Washington 98052-6399 Re: Microsoft Corporation Registration Statement on Form S-4 Filed February 16, 2021 File No. 333-253138 Dear Mr. Nadella: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rule 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in his absence, Larry Spirgel, Office Chief, at (202) 551-3815 with any questions. Sincerely, Division of Corporation Finance Office of Technology